William McCoy said the committee received more than 150 comments during the 2011 review. The input helped the committee in clarifying many aspects of the standard. Changes being proposed to the third review based on that input include:

Clarifications made to definitions in section 3, definition of terms and a new term was defined; and clarifications made to section 5, risk characterization. Those changes were substantive because building characteristics were reorganized into two subsections for clarity, subsections 5.2 and 5.3; reorganization of table 1, determining preventative measures required for buildings. The improvements reference two subsections of section 5 (sec. 5.2 and 5.3); and the creation of a new subsection, 7.4, water system treatment and management program, in section 7. Commenters indicated there should be specifications for a water system treatment and management program for buildings with none of the risk characteristics (now listed in sec. 5.2), but with any of the equipment specified (now listed in sec. 5.3); clarifications to section 8 regarding wording, references, cited regulations, and informative notes.

Compliance with the standard requires facility managers and owners to formally take responsibility for controlling legionella in their building water systems, while at the same time acting as a defense against accusations of negligence in those cases which are caused by the hazard from unknown sources.

Standard 188P also covers the potable water system in buildings, which are not treated as often as cooling towers, and will hold facility managers/owners accountable for properly managing the entire building water system both potable and utility water.

Publication date: 3/4/2013